We are Incentifi Ltd, a company incorporated in England and Wales. Our company number is 14594220 and our registered office is at 85 Great Portland Street, London, W1W 7LT. Incentifi Ltd are committed to ensuring that User privacy is protected. Incentifi Ltd will continue to comply with the provisions of the General Data Protection Regulation ((EU 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, including the Data Protection Act 2018 (“DPA”) and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). Incentifi Ltd are the data controller of data User pass to Incentifi Ltd pursuant to this policy.

This privacy policy together with Incentifi Ltd’s cookie policy sets out how Incentifi Ltd collect personal data from User in the use of the App and/or Services and how the personal information User provides will be processed by Incentifi Ltd. By using the App and/or Services User is accepting and consenting to the practices described in this privacy policy. If User does not consent, User should not submit any personal data to Incentifi Ltd.

1.1 What information Incentifi Ltd hold and how Incentifi Ltd will use it:

1.1.1 Information User gives to Incentifi Ltd:

User may give Incentifi Ltd information about User by using the App and/or Services. The information User gives Incentifi Ltd may include User name, email address/location and phone number. Incentifi Ltd will retain this information while corresponding with User and then for a further period of two years.

1.1.2 Information Incentifi Ltd collect about User:

Incentifi Ltd may collect the following information from User when User visits Incentifi Ltd’s App and uses the Services:

  • 1.1.2.1 technical information, including the Internet protocol (IP) address used to connect User’s mobile device, mobile application or computer to the Internet, User’s login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

  • 1.1.2.2 information about User’s visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the App (including date and time), products and pages User has viewed or searched for, page response times, App errors, length of visits to certain pages in the App, App interaction information, methods used to browse away from the page and any phone number used.

1.1.3 Information Incentifi Ltd receive from other sources:

This includes information Incentifi Ltd receive about User when User uses other apps operated by us or other services we provide. This information may include your name, email address, postal address and phone number.

1.2

The App uses cookies to distinguish User from other users of the App. For detailed information on the cookies Incentifi Ltd use and the purposes for which Incentifi Ltd use them, User should review Incentifi Ltd’s Cookie Policy at https://incentifi.io

1.3 Use of information (with consent where required):

Incentifi Ltd may use the information that Incentifi Ltd receive and/or collect about User to:

  • 1.3.1 fulfil Incentifi Ltd’s obligations under any contract Incentifi Ltd have entered into with User and to provide User with information, products and services User has requested;

  • 1.3.2 send User newsletters and marketing information if User has consented to Incentifi Ltd doing so or if permitted under Data Protection Legislation;

  • 1.3.3 notify User of products and services Incentifi Ltd offer that are similar to those User has purchased or enquired about;

  • 1.3.4 notify User of other products and services Incentifi Ltd feel may interest User, or permit third parties to do so if User has consented;

  • 1.3.5 notify User of changes to Incentifi Ltd’s services and products; and

  • 1.3.6 monitor App and/or Services usage and provide statistics to third parties to improve and develop the App and Services.

1.4 Processing based on legitimate interests:

Incentifi Ltd process personal data based on legitimate interests, including:

  • 1.4.1 improving App/Services and communication;

  • 1.4.2 fraud prevention;

  • 1.4.3 securing networks and systems;

  • 1.4.4 understanding user interaction with App/Services;

  • 1.4.5 troubleshooting and data analysis;

  • 1.4.6 evaluating promotional campaigns.

1.5 Contractual necessity:

If personal data is needed to fulfil a contract, Incentifi Ltd may not be able to proceed without it.

1.6 Consent:

Where legitimate interest or other legal bases do not apply, Incentifi Ltd will obtain User consent before processing.

1.7 Third-party marketing:

With consent, Incentifi Ltd may share personal data with third parties for marketing.

1.8 Withdrawing consent:

User can withdraw consent at any time by contacting [email protected]. This won’t affect prior lawful processing.

1.9 Marketing opt-out:

To unsubscribe from marketing communications, click “unsubscribe” in emails or contact [email protected].

1.10 Data sharing:

Incentifi Ltd will not share personal data except as stated in this policy or required by law.

1.11 Security:

Passwords provided to access the App/Services must be kept confidential.

1.12 Safeguards:

Incentifi Ltd use various security technologies to protect User data.

1.13 Transmission risk:

Transmission of information via the App is at User’s own risk.

1.14 Sharing with third parties:

May include:

  • 1.14.1 suppliers for contract performance

  • 1.14.2 third-party marketers with consent

  • 1.14.3 advertisers/analytics partners

1.15 Legal disclosures:

Incentifi Ltd may disclose personal data when:

  • 1.15.1 buying/selling a business;

  • 1.15.2 required by law;

  • 1.15.3 protecting rights, property, or safety.

1.16 Data transfers outside the EEA:

Transfers will occur only with appropriate safeguards or adequacy decisions.

1.17 User rights:

Access:

Request confirmation, access, and copies of data.

Rectification:

Request correction of inaccurate data.

Erasure:

Right to be forgotten under specific circumstances.

Restriction:

Pause processing under specific conditions.

Objection:

Object to processing under legitimate interests or for marketing.

Portability:

Request data in a machine-readable format (applies to data provided by User, processed with consent/contract, and automated).

1.18 Complaints:

Contact Incentifi Ltd or report to the ICO: https://ico.org.uk/concerns/, or call 0303 123 1113.

1.19 Contact:

For queries or rights requests, contact [email protected]